Market participants may need to amend derivatives contracts in response to interest rate benchmark reforms. If amendments to legacy derivatives contracts are made solely to address interest rate benchmark reforms, they do not require the application of the margin requirements for the purposes of the framework. (Amended swaps are often considered new swaps for purposes of application of new rules.) However, the guidance notes that this position may be different under relevant jurisdictional implementing laws.

In the remaining phases of the framework's implementation in 2019 and 2020, initial margin (IM) requirements will apply to a large number of entities for the first time and will potentially involve new documentation, custodial, and operational arrangements. BCBS and IOSCO note that the framework does not specify documentation, custodial, or operational requirements if the bilateral IM amount does not exceed the framework's €50 million IM threshold. However, covered entities are expected to act diligently when their exposures approach the threshold to ensure that the relevant arrangements needed are in place if the threshold is exceeded.